Larry Bruce - Page 5




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               Petitioner filed the petition on December 27, 2005.  In it,            
          petitioner stated that he was appealing the notice of                       
          determination and wanted a redetermination of the additions to              
          tax.  The only specifically listed errors, as required by Rule              
          331, were:  (1) That petitioner was denied his right to a fair              
          hearing; (2) that the filing of the Notice of Federal Tax Lien              
          was erroneous; and (3) that the balance due on the Notice of                
          Federal Tax Lien was erroneous.                                             
                                     Discussion                                       
               Respondent moved for summary judgment on all issues pursuant           
          to Rule 121.  Summary judgment is intended to expedite litigation           
          and avoid unnecessary trials.  Fla. Peach Corp. v. Commissioner,            
          90 T.C. 678, 681 (1988).  A motion for summary judgment may be              
          granted if there is no genuine issue as to any material fact and            
          a decision may be rendered as a matter of law.  See Rule 121(b);            
          Electronic Arts, Inc. v. Commissioner, 118 T.C. 226, 238 (2002).            
          The moving party bears the burden of showing that there is no               
          genuine issue of material fact, and factual inferences will be              
          read in a manner most favorable to the party opposing summary               
          judgment.  Bond v. Commissioner, 100 T.C. 32, 36 (1993);                    
          Dahlstrom v. Commissioner, 85 T.C. 812, 821 (1985).  The party              
          opposing summary judgment must set forth specific facts which               
          show that a genuine question of material fact exists and may not            








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